Access to Care
We receive frequent calls regarding the process of involuntarily discharging a patient under the Conditions for Coverage (CfC). Let us first emphasize that involuntary discharge should be the option of last resort. Discharged patients are at high risk for morbidity and mortality. Facilities should train staff in conflict management techniques and work to remove any barriers that patients may be facing.
The Network's Role in Preventing and Reducing Involuntary Discharges
- The patient or payer no longer reimburses the facility for the ordered services
- The facility ceases to operate
- The transfer is necessary for the patient's welfare because the facility can no longer meet the patient's documented medical needs
- The facility has reassessed the patient and determined that the patient's behavior is disruptive and abusive to the extent that the delivery of care to the patient or the ability of the facility to operate effectively is seriously impared
- There is an immediate severe threat to the health and safety of others
Types of Involuntary Discharge
- Involuntary Discharge (IVD): an involuntary discharge is a discharge initiated by the treating dialysis facility without the patient's agreement
- Involuntary Transfer (IVT): an involuntary transfer occurs when the transferring facility temporarily or permanently closes due to a merger, or due to an emergency or disaster situation, or due to other circumstances, and the patient is dissatisfied with the transfer to another facility
- Failure to Place: a situation in which no outpatient dialysis facility can be located that will accept an ESRD patient for routine dialysis treatment
Working with the Patient
The Network has resources for healthcare providers to assist in clinical practice and to deal with difficult situations. If you are having difficulty placing a patient in an outpatient dialysis facility, your first resource is Medicare Compare to search and compare dialysis facilities in the United States and Territories. If you are still having issues placing patients in outpatient dialysis facilities, please contact Network Staff to discuss options and potential interventions for overcoming barriers to placement.
If provider staff is dealing with a situation that they feel may warrant a patient's involuntary discharge (IVD) or transfer (IVT), please be aware that the Network and State Department of Health MUST be notified when ANY notice of termination or transfer is given to a patient. IVD/IVT places patients at extreme risk and should be considered ONLY as a last resort. IVDs and IVT's are tracked by the Network and reported to CMS monthly. In addition, patients who do not have a Health Care Proxy or Emergency Contact Person are also considered at-risk. In many cases, we have found that early interventions have prevented discharge and we urge facility staff to identify patients who are at risk early and to contact the Network's Patient Services department for assistance.
Tools & Resources
- V-Tags and Patient Involuntary Discharge: Interpretive Guidance
- Dialysis Facility Involuntary Discharge Guidelines: Network 1 | Network 2 | Network 6 | Network 9
- Decreasing Dialysis Patient-Provider Conflict (DPC): Provider Manual
- CMS Conditions for Coverage for ESRD Facilities: Interpretive Guidance